Labor Department spokesman Leo Rosales said the new regulations result from a 2008 law that empowered the labor commissioner to "safeguard the health, education, morals and general welfare of child performers."

Rosales said the rules, quietly proposed in November, could be altered. A public hearing is set for Jan. 31.

"This is part of the process," Rosales said. "We want their comments because we are going to look at them very closely to see if any changes need to be made."

Nancy Fox of the Screen Actors Guild warned the new rules could drive film and TV productions to less restrictive states. "You want to make sure New York is as user-friendly as possible," Fox said.

Fox said SAG objects to what it believes is an overly burdensome requirement that parents of child actors obtain medical certifications every six months declaring that their children are fit to work.

SAG fears the new regulations do not guarantee "sight and sound access" - the ability of parents to hear and see their children at all times.

"It really just comes down to the Department of Labor didn't understand what they were doing and they did it anyway," said Linda Crisp, the parent of an 11-year-old actor and founder of the Child Performers Coalition.